United States Environmental Protection Agency
Region II
POLLUTION REPORT



Date:
Friday, April 13, 2007
From:
Paul L. Kahn & Eric M. Daly

To:
Mary Mears, USEPA, Region 2, PAD
Carole Petersen, USEPA, Region 2ERRD-NJRB
John Kushwara, USEPA Region 2 DECA-WCB
Patricia Carr, USEPA-PAD
Fred Mumford, NJDEP
Marissa Truono, USEPA ERRD-RAB
Walter Andrews , USEPA Region 2 DEPP-WPB
George Zachos, USEPA Region 2 ERRD
Andrew Radaant, US DOI
Dave Sweeney, NJDEP
Tim Grier, USEPA Headquarters 5202G
Kristin Grun, NJDEP
Joshua Gradwohl, NJDEP
Paul King, NJDEP
Carol Chamberlain, Lawrence Township Health Dept.

Subject: 

Friction Division Products
40 North Enterprise Ave, Lawrence Township (Trenton), NJ
Latitude: 40.2728000
Longitude: -74.7083000


POLREP No.:
23
Site #:
XW
Reporting Period:
D.O. #:
031
Start Date:
6/26/2006
Response Authority:
CERCLA
Mob Date:
1/28/2007
Response Type:
Time-Critical
Demob Date:
 
NPL Status:
Non NPL
Completion Date:
6/26/2007
Incident Category:
Removal Action
CERCLIS ID #:
NJN0002058677
Contract #
EP-W-04-055
RCRIS ID #:
 

Site Description

This Site, a defunct automotive brake pad manufacturer, was brought to the attention of EPA by the NJDEP for a possible referral for a CERCLA removal action.  An inspection by EPA OSCs and a DEP responder on 12/23/05 revealed the following hazardous materials/wastes were abandoned at the site:  tons of asbestos material, tons of elemental sulphur, 1,000+ drums of mostly unknown materials or materials that do not match the label description, hundreds of smaller containers, acids, flammable liquids, iron and aluminum powders, flammable solids, waste oil, solvents, and other contaminants or pollutants.  The Site is semi-controlled, with most doors being locked but numerous open windows or sections of sheet-metal walls missing.  A maintenance man is on-site for a few hours Mon-Fri.  

During June, 2006, the OSC observed that employees of the RP, Friction Division Products, were entering the Site and loading contaminated drums and debris in a roll-off from Building #7.  In the process of removing the contaminated debris they managed to spill powdered chemicals from broken bags on a pallet.  EPA brought this to the attention of the property owners.  With  EPA management authorization, and the owner's permission, EPA initiated security guard service as of June 15, 2006 to prevent access by the RP and other unauthorized persons.  Security guard service was discontinued on June 26, 2006, when RP agreed to not enter the Site unless EPA was present.


Current Activities

ERRS continues to bulk/consolidate compatible chemicals into discrete waste streams.  Waste chemcial handling is about 75% complete.

OSC Daly continues to work with ERRS contractor to draft work plan to address ACM contained in each of 10 baghouses and 3 waste piles at the Site.  He is coordinating this information with local health department officials.  OSC Kahn has prepared a draft Action Memo requesting an increase in mitigation contractor funding level.   To the extent needed, the additional funds will be used to cover the cost of the baghouse project, within the overall scope-of-work of the removal action.

OSC has been informed by a number of individuals involved in the automotive scrap business that there isn't any resale or recycling market for finished disc brake pads.  This topic will be addressed at a future time in detail in a special POLREP.


Planned Removal Actions

ERRS will continue to process chemical wastes into compatible waste streams for disposal.

EPA/ERRS will continue to work on the plan to address the ACM on the Site.

The Site will be temporatily demobed for the week of 4/23/07 to allow the ERRS contractor crew to go home for a break.  Upon remobing on 4/30/07 the work plan for the baghouse project will be implemented and the baghouses will be prepared for removal and staging at the on-Site processing area.

Sample floor in Building #8 for the possible presence of asbestos fibers.


Next Steps

Continue processing chemicals for disposal.  Finalize draft work plan/implement plan to address ACM on the Site.


Key Issues

Chemical handling and asbestos remediation.


response.epa.gov/frictiondivision